IMPERIO GROUP ANTI-BRIBERY POLICY STATEMENT

Introduction

Imperio Group values its reputation for ethical behaviour and integrity. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. The purpose of this Policy Statement is to set out for Board members, employees, clients and business partners of the Group the aim of limiting its exposure to bribery by:

– Setting out a clear anti-bribery policy;
– Training all employees and Board members so that they can recognise and avoid the use of bribery by themselves and others;
– Encouraging our employees to be aware and to report any suspicion of bribery, in a manner which provides them with a safe and reasonable assurance of sensitive handling;
– Rigorously investigating instances of alleged bribery and assisting police and other appropriate authorities in any resultant prosecution;
– Instigating the most severe disciplinary action against any individual(s) involved in bribery and informing the appropriate authorities.

Scope

This Policy Statement applies to Directors, employees, clients and business partners who work for or with any company of the Group.

-The Group prohibits the offering, giving, solicitation or acceptance of any bribe, whether cash or other inducement;
-To or from any person or company, wherever they are situated and whether they are a public official or body or private person or company;
-By any individual employee, Director, Board Member, agent or other person or body acting on behalf of the Group, or any of its subsidiaries;
-In order to gain any commercial, contractual, monetary, or regulatory advantage for any of the companies of the Group or themselves or any other in a manner which is unethical, immoral or illegal.

Further clarification

This policy statement prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Group or of the person or body employing them or whom they represent.

Corporate hospitality
This policy is not meant to prohibit the practice of corporate hospitality providing this is customary, proportionate and properly recorded, nor is this policy intended to prevent the giving of a gift of an appropriate value at a time of seasonal festivities or other important date. If you are at all unsure as to whether any gift or form of hospitality is appropriate or not, speak to your Line Manager or Compliance Officer for clarification.

Business gifts
All offers of business gifts should be referred to the Compliance Officer and offers should only be accepted or made following clearance from them. Where business gifts are accepted or provided details of the gift and the reason for the gift should be provided to the Compliance Officer who will retain a record.

The provision of small promotional gifts such as diaries, pens or similar marketing collateral are generally regarded as acceptable however if there is any doubt please refer to the Compliance Officer.

Whistle-blowing
If you are concerned that a corrupt act of some kind is being considered or has been carried out, either within the Group or by any of our business partners or our competitors, then you must report the issue/concern to your line manager and/or the Compliance Officer. Failure to report an incidence of bribery will result in disciplinary proceedings.

If you are an employee and feel unable to raise the issue with your Line Manager, then you should contact the Compliance Officer directly. All communications with the Compliance Officer are entirely confidential, and no employee is at any risk of any retaliation for reporting an incidence in good faith.

Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to your Line Manager. If necessary, guidance should also be sought from the Compliance Officer.

Employee and Board responsibility

The prevention, detection and reporting of bribery is the responsibility of all employees and Directors throughout the Company. This document forms part of our standard terms and conditions of employment for all employees.

Any questions relating to the Anti-Bribery Policy should be referred to the Compliance Officer:
Yiannis Misirlis
+357 25 581005
yiannis@imperio-group.com